Guerrilla Discovery

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State and Federal (This started in the new 2019 edition)


Guerrilla Discovery is a complete, comprehensive arsenal of information specifically tailored for planning, conducting and executing discovery. It likewise provides defensive information and counteroffensive chess-like strategies for every discovery attack. Guerrilla includes:

  • Extensive Case Citations
  • Updated Rules
  • Detailed Strategies for the 6 Discovery Devices:
    • Depositions
    • Requests For Admissions
    • Interrogatories
    • Notice For Production
    • Notice For Inspection
    • Notice For Physical/Mental Examinations
  • Model Forms (For all devices)
  • Extensive Annotated Forms
  • Comprehensive and Extensive Form Interrogatories
  • Extensive Checklists
  • A List of Every Possible Defense and Opposition to Discovery
  • Sample Motion Arguments
  • Sample Deposition Questioning
  • Mini-Crash Courses in Evidence
Most lawsuits are engulfed in quarrelsome discovery fights. Coercion and confrontation are often necessary to obtain evidence on the hotly-contested issues. To help you win more of these important discovery skirmishes, Ashley Lipson’s Guerrilla Discovery offers dozens of clever strategies, novel arguments, direct answers, cautionary instructions, helpful timelines, tactically-annotated rules, and over one hundred innovative forms that will help you:
  • Capture evidence establishing your claims and defenses
  • Secure admissions
  • Settle issues and disputes
  • Impeach the opposition and its witnesses
  • Uncover what the opposition is hiding
  • Learn what the opposition has on you
  • Handle defiant deponents and uncooperative attorneys
  • Control the complexities of e-discovery

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